EASA stipulate that we log IFR time in a separate entry.
They then require certain amounts of it for different reasons for certain things single crew ops IFR commercial flights is one of them.
So heading off down the what is and isn't and do you require a safety pilot isn't really helpful.
What the guy wants to do is go off with a student on a nav-ex fly it at IFR levels etc then claim the flight as IFR to get his numbers up.
The plane more than likely isn't IFR fitted and legal and he will be looking out the window the whole time more than likely never touching the controls.
But he wants the time to get a job. The fact that he more than likely isn't qualified to teach instrument flying and will also be logging the flight as instructor just complicates things further.
Any post holder in a AOC should laugh at it. If a flight ops inspector see's it they certainly won't laugh.
But the op isn't the first and won't be the last to try and get round that regulation.